Florida Appeals successfully defended an order denying a motion to quash personal service on behalf of an injured motorist in the Fourth District Court of Appeal. The nonresident driver challenged substituted service of process under Florida Statutes 48.171 and 48.161 and argued the Hague Service Convention was not followed. Florida Appeals’ arguments in support of the lower court’s order included that the nonresident driver failed to specifically raise the Hague Service Convention, that substituted service on a nonresident driver in Florida falls outside the scope of the Hague Service Convention, and that the nonresident driver’s refusal to accept delivery barred him from challenging statutory notice under FS 48.161. The Fourth District affirmed the trial court’s order on November 4, 2021.